1. India Comments on
EPPR

2. Comment-1 :
Clause 4: Definition
IMMA proposal is to keep all the definition in this document in alphabetical order. This can be accepted and its also suggested that all the definition in existing GTR-18 on OBD-1 can be also set in the alphabetical order.
Comment-2 :
Definitions
Mono-fuel vehicle
Powertrain Calibration
Powertrain Control Unit
Powertrain software
IMMA Comments: Propose to delete because not used in this GTR2
India Comment:
India does not agree to delete these definitions from GTR 2.
These are required for GTR 18 ( Current and Proposed amendement under formulation in OBD2CG).
In case EPPR agrees to delete these definitions need to be incorporated in GTR 18 itself.

3. Comment-3:
Table -6 : Principal performance requirements under column reference fuel for PI & CI class mentioned references given for fuel are mentioned as Annex 40 which is not correct, it should be annex 4. This correction was proposed by India earlier.
Table 7 Foot note 2: Applicable parts of driving cycle for Alt A are part 1 RS  cold and part 1 RS  hot, as  against Euro 4 part  1 RS  cold and part 2 RS  hot
Comment-4:
 IMMA Comments to change HC to THC and also to define RS can be included in a table of abbreviation and this table can be created.
Similar such kind of terms can be brought under table of abbreviation for better clarity.
Term
Meaning HC
Total Hydrocarbon
THC RS
Reduced Speed
RST25 
Reduced speed truncated at 25kmph
RST45
Reduced speed truncated at 45kmph

4. Comment-5 :
If IMMA would like to remove the Note number then the notes should be shifted to relevant clause.
Comment-6
clause no : India has already given comments on equation no 7 to replace Mk by Mref
Comment-7:
Clause no : IMMA comment to add term ma in this clause for the sum of mass in running order is not appropriate As term ma is defined as actual mass in the table of symbols.
Comment-8:
Clause no : As IMMA proposed to change GDI to DI, we recommend to replace GDI by Gasoline direct injection. However GDI is term used in most of the international regulation in different way.

5. Comment-9:
Clause no , , & : IMMA comments to be justified, however India feels Two wheeler configuration with twin wheel will require this clause.
Comment-10:
Clause no: : IMMA comments to use “x” for multiplication in the formulae to be verified by secretariat to maintain the uniformity across the GTRs.
Comment-11:
Annex-2 clause no 5.3. :
India Comment: (CCO + CCO2) is at least 15% for petrol (E5)    
Justification:  Delete E5 and made it applicable for all.

6. THANKS